Facing financial crime: When should firms use on-demand financial crime expertise 

For financial services businesses, operational agility is fast becoming imperative. Across banking, wealth and insurance, firms are finding it harder to access senior leadership expertise at pace, particularly as financial crime accelerates, regulatory expectations intensify and supervisory scrutiny becomes more forensic. Permanent hiring remains the default response, yet it carries significant cost, commitment and risk that not every business can comfortably absorb.

The scale of the threat remains substantial. The Office for National Statistics estimated around 4.5 million fraud incidents in England and Wales in the year ending March 2026, with the number of victims increasing by 10% compared with the previous year.

This exposes a fundamental weakness in traditional operating models: threats move across functions and technologies, while specialist capability and ownership often remain fixed within them. Firms therefore need more than additional controls or headcount. They need an operating model that combines institutional knowledge with the ability to deploy specialist capability quickly.

As a result, some firms are rethinking how much of their leadership capacity genuinely needs to be fixed. Agile resourcing models provide a useful approach to protecting core operations while retaining the ability to scale senior leadership capacity when regulations change or transformation programmes intensify. Across recent speeches and strategic updates, the FCA has consistently reinforced a central message: no single organisation can fight financial crime alone. The regulator has emphasised the need for collective action, public-private sector coordination and greater resilience. 

That’s why specialist resourcing becomes a strategic delivery lever when firms organise it around defined regulatory and operational outcomes, rather than treating it as a faster route to filling vacancies. It gives organisations access to experienced subject-matter experts as business demands evolve, helping them scale capability without embedding unnecessary permanent overhead.

With a defined mandate, clear reporting lines and appropriate senior oversight, experienced specialists can lead delivery quickly while accountability remains firmly governed.

The result is faster execution, reduced disruption and greater operational resilience. Teams can maintain momentum, deliver critical programmes and stay focused on longer-term strategic priorities, as Joe Norburn, CEO at TCC and Momenta, explains…

Why are traditional financial crime resourcing models under pressure?

Criminals exploit the gaps between institutions, jurisdictions, technologies and internal teams, often faster and more effectively than firms can respond. Ownership is often divided across operations, compliance, fraud, cyber and technology, each with different priorities, data sets and measures of success. Controls may appear robust in isolation, yet weaknesses often emerge at the points where teams, systems and processes intersect.

That fragmentation creates operational risk and compounds vulnerability. Issues identified in one area may lack the context, ownership or specialist support needed to drive an effective response elsewhere. As threats evolve and regulatory expectations increase, firms need operating models that can combine organisational stability with the ability to mobilise additional capability when circumstances demand it.

A strong core team provides continuity, retaining valuable knowledge of the firm’s culture, systems and financial crime risk landscape, while access to specialist support enables organisations to respond quickly to changing priorities and developing pressures.

For boards, the issue is not simply headcount. It is whether the organisation has enough accountable capability to maintain effective control, respond to emerging threats and deliver change without creating an inefficient cost base. That requires deliberate decisions about which expertise must remain embedded and which can be mobilised around specific risks, programmes or periods of scrutiny.

In financial crime, this distinction matters. A firm needs in-house ownership of its financial crime risk appetite, governance and regulatory accountability, but not necessarily permanent capacity for every remediation programme, control review or transformation requirement. Specialist leaders, subject-matter experts and delivery teams can be deployed around clearly defined outcomes, while responsibility remains firmly within the firm’s governance structure. 

This flexible capability can support defined requirements such as regulatory remediation, financial crime transformation, risk uplift, data reviews or supervisory response. It can also provide integrated teams with the leadership and delivery capability needed to solve complex challenges without creating unnecessary long-term structural cost.

Building capability without losing control

The model only works when implemented with clear intent. Specialist resourcing should be designed around the firm’s risk profile, required outcomes and governance arrangements, rather than approached as a transactional staffing exercise. 

Boards and executive teams need clarity on what problem is being solved. Is this a one-off leadership requirement? A fully mobilised project delivery team? Additional compliance oversight during regulatory scrutiny? Or ongoing flexible capacity to bridge cyclical demand?

A bespoke approach matters. Every firm has a different operational rhythm, governance structure and risk profile. In practice, the balance may look slightly different depending on the organisation’s maturity, supervisory environment and growth ambitions. What remains constant is the principle: protect the core, flex where it counts.

Experience also matters. Interim leaders who understand SM&CR accountability, board dynamics and regulatory engagement are more likely to embed effectively and avoid creating additional oversight risk. Critically, the most effective interim leaders operate as accountable operators rather than external advisors. They smoothly and quickly integrate into the organisation, making decisions and taking responsibility for delivery in complex, regulated environments.

When should firms use on-demand financial crime expertise?

Firms should consider specialist, on-demand support when a risk or delivery requirement is material, time-bound and beyond available internal capacity. Typical triggers include regulatory engagement, remediation backlogs, control failures, transformation programmes, leadership gaps, rapid growth or the need for independent challenge. Before deployment, firms should define the mandate, reporting lines, responsibility, intended outcomes and exit plan.

Financial crime is a clear example of where this model can add value. Historically, financial crime prevention was often viewed as a standalone compliance requirement focused on regulatory obligations. Today, it is increasingly connected to customer outcomes, operational resilience and public trust. 

Experienced change and transformation leaders can step in and take ownership immediately, leading large-scale programmes across people, process and technology. In highly regulated environments, they balance pace with compliance to ensure measurable business value without compromising risk standards.

Senior compliance leaders such as Chief Risk Officers, Chief Compliance Officers or Heads of Monitoring provide immediate credibility during regulatory change or supervisory engagement. They strengthen frameworks, stabilise governance and reassure stakeholders without increasing permanent headcount.

Project delivery teams can be mobilised for AML and KYC remediation, transaction-monitoring transformation, customer-file and data-quality reviews, or regulatory response. These integrated teams bring together experienced leaders, programme managers, business analysts, financial crime specialists, data experts and quality-control professionals under the firm’s governance and defined accountability. This gives firms end-to-end delivery capability without embedding the full programme structure as a permanent cost. 

How firms can scale financial crime capability without weakening control

In practice, effective financial crime oversight is not about adding more standalone controls. It is about making sure the controls a firm already has operate as part of a coherent system. 

Scaling a financial services business in today’s world requires precision. Over-hiring locks in unnecessary cost, yet under-resourcing increases risk. The agile resourcing approach offers controlled scalability: matching resources to risk at the right moment.

It reduces the financial drag of overcapacity, limits the disruption caused by redundancy cycles and minimises leadership vacuums during critical moments. At the same time, it ensures that specialist capability is deployed with focus and impact when it is genuinely needed. 

External collaboration is rightly rising up the agenda, but it will only be effective if firms understand – and address – fragmentation inside their own organisations. The next phase of financial crime management will be defined less by individual controls or technologies, and more by how well firms operate as joined-up systems.

The question is not whether every financial crime capability should be in-house. It is whether firms have the experienced leadership, accountability and capacity at the moments of greatest risk. A stable core supported by specialist, on-demand capability gives firms continuity without sacrificing speed, flexibility or control.